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EU AI Act: High-Risk Deadlines Move

July 21, 20262 minute read

Two high-risk compliance deadlines just moved. The transparency deadline did not. It hits on 2 August.

On 29 June, the EU Council gave final approval to the AI Act Digital Omnibus — the first substantive amendment since the Act’s 2024 adoption. High-risk obligations for standalone Annex III systems are deferred to 2 December 2027. For AI in regulated products, to 2 August 2028. The final text was signed on 8 July and awaits Official Journal publication.

Article 50 transparency obligations remain on their original schedule: 2 August 2026.

From that date, every AI system interacting with people must disclose that the user is communicating with an AI. Synthetic content must carry machine-readable labels. Deepfakes must be disclosed. Emotion recognition and biometric categorisation systems must inform the individuals being processed. Fines reach €15 million or 3% of global annual turnover.

The Omnibus also introduces new prohibited practices from 2 December 2026: AI-generated non-consensual intimate imagery and CSAM are explicitly banned.

What this means for your compliance team:
→ The deferral is not a general reprieve. Transparency, prohibited practices, and GPAI obligations were not deferred. Only high-risk classification moved.
→ Chatbot disclosure must be timely and clear — at the point of interaction, not buried in terms of service. Audit your AI-facing interfaces before 2 August.
→ Synthetic content labelling applies to the content itself, not just the hosting platform. If you generate AI content for commercial use, the marking obligation is yours.
→ Track both timelines: 2 August 2026 (transparency enforceable) and 2 December 2027 (high-risk for standalone systems). Planning for one without the other creates a compliance gap.

At S8fe.ai, we help organisations map their data inside AI deployments against the regulatory obligations that actually apply to them — so compliance planning reflects the timelines that are live, not the ones that moved.

The high-risk deadlines moved. The transparency deadline did not.

Sources:
• https://www.consilium.europa.eu/en/press/press-releases/2026/06/29/artificial-intelligence-council-gives-final-green-light-to-simplify-and-streamline-rules/
• https://www.gibsondunn.com/eu-ai-act-omnibus-agreement-postponed-high-risk-deadlines-and-other-key-changes/
• https://compliancehub.wiki/eu-digital-omnibus-ai-act-deadline-deferral-annex-iii-2027/

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